Financial Crime World

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Comprehensive Compliance Program

This comprehensive compliance program outlines key components to ensure adherence to anti-money laundering (AML), know-your-customer (KYC), and other regulatory requirements.

1. Error Correction Process

The error correction process ensures that errors in transactions above Rs. 1,000,000/- are identified, reported, and rectified.

  • Identify Errors: Identify errors in transactions above Rs. 1,000,000/-
  • Report Errors: Report errors to relevant departments (Compliance, Channel Management)
  • Update Core Banking System: Update Core Banking System with correct information
  • Confirm Rectification: Confirm rectification of errors and system updates

2. Department Assessments

The Compliance Department conducts assessments on core departments/units based on specific criteria.

  • Assessment Criteria:
    • Direct Responses: Yes- 1 mark, No- 0 marks
    • Detailed Responses: Not complied- 1 mark, Complied up to 50%- 2 marks, Complied up to 75%- 3 marks, Fully complied- 4 marks
  • Risk Rating: Risk rating based on total marks obtained:
    • 00-29 - Poor
    • 30-59 - Average
    • 60-89 - Good
    • 90-100 - Excellent

3. Reviews

The Compliance Department reviews branch assessments conducted by Regional Compliance Officers on a sample basis.

  • Review Frequency: Quarterly review of 4 branches/month
  • Risk-Based Approach:
    • Poor: Re-visit within 6 months
    • Average: Re-visit within 1 year
    • Good: Re-visit within 18 months
    • Excellent: Re-visit within 2 years

4. Assessment of Subsidiary

The quarterly questionnaire (Annexure 7) for People’s Leasing and Finance PLC is reviewed.

  • Quarterly Questionnaire: Quarterly questionnaire (Annexure 7) for People’s Leasing and Finance PLC
  • On-Site Review: On-site review every 2 years

5. Training

In-house training is conducted on various compliance-related areas.

  • Training Topics:
    • AML/KYC, CDD Measures, Risk Categorization, Reporting Suspicious Transactions, Right to Information Act, AML System, and other compliance-related areas

6. Reporting Requirements of FIU

Reports are generated and forwarded to the Branch Network for error correction and system updation.

  • Report Transactions: Report transactions over Rs. 1,000,000/- to the Financial Intelligence Unit (FIU)
  • System Updation: Reports generated by the system will be forwarded to the Branch Network for error correction and system updation

7. Foreign Exchange Compliance

Activities are conducted in compliance with Foreign Exchange regulations.

  • Foreign Exchange Regulations: Conduct activities in compliance with Foreign Exchange regulations issued from time to time
  • Directions, Circulars, and Instructions: Directions, Circulars, and instructions issued by the Department of Foreign Exchange should be followed.